(231) It can therefore be accepted that the duration of 12 years would not exceed the depreciation period of the most significant assets used by Correos for the provision of the USO as required by the 2012 SGEI Framework.
D.
Compliance with Commission Directive 2006/111/EC
(74).
(232) According to paragraph 18 of the 2012 SGEI Framework, ‘aid will be considered compatible with the internal market on the basis of Article 106(2) of the Treaty only where the undertaking complies, where applicable, with Directive 2006/111/EC on the transparency of financial relations between Member States and public undertakings as well as on financial transparency within certain undertakings’.
(233) Article 29 of the 1998 Spanish Postal Law imposes separate accounts within the internal accounting system of the universal service provider.
(234) This obligation is notably implemented through Order FOM/2447/2004 of 12 July on ‘analytical accounting and separation of accounts’. The Commission has verified that the principles established in that regulation are in line, in terms of allocation of direct and incorrect costs, with the principles established in the 2012 SGEI Framework (75).
(235) Moreover, following the request of the Commission in the 2016 Opening Decision, the Spanish authorities have provided the Commission with a detailed description of the analytical accounting system of Correos which is summarised in the figure.
Cost allocation system of Correos
[Bild bitte in Originalquelle ansehen]
Subreparto de Costes de Estructura
Imputación Directa
Coste por Producto/Servicio
Imputación Actividades a Productos
CeCo's Operativos
Imputación de Costes a CeCo's
Costes Indirectos
Costes Directos
Imputación de CeCo's a Actividades
Imputación de Costes a CeCo's
Contabilidad Financiera
Volumen
Tiempo
Costes por Actividad
CeCo's Estructura
(236) As illustrated in recital 235, the Correos cost accounting system is based on the cost accounting methodology called activity-based costing. The activity-based costing system is a particular method of the fully distributed cost allocation method, which complies with the applicable provisions of the 2012 SGEI Framework (76) and is also in line with the sector specific requirements on separate accounting laid down in Article 14 of the Postal Services Directive.
(237) The analytical model of Correos contains essentially the following phases:
(1) Determination of the costs to be imputed from the Profit & Loss account: In 2005, the imputable costs amounted to approximately EUR […] billion.
(2) Imputation of costs to cost centers:
(a) A small percentage of the costs ([…] % — approx. EUR […] million in 2005) is imputed directly to final products.
(b) The bulk of the imputable costs ([…] %— EUR […] billion) is imputed to cost centers (CeCos).
The CeCos (there were […] CeCos in 2005) are the basic unit of the analytical accounting system. They are defined as unit of consumption of resources which are relevant from a cost accounting viewpoint.
The analytical accounting system of Correos distinguishes between:
— operational CeCos: which consume resources that are directly related to the final products and services (e.g. post office). There were […] operational CeCos in the analytical accounting system of Correos in 2005. An amount of EUR […] billion was imputed to operational CeCos in 2005.
— structural CeCos: which concentrate the structural costs which are not directly related to final products and services. These correspond notably to the support, administration, human resources management, IT functions. There were 180 structural CeCos in the analytical accounting system of Correos in 2005. An amount of EUR […] million was imputed to structural CeCos in 2005.